NDIS restrictive practices: what implementing providers must record and report
An NDIS provider that uses regulated restrictive practices is an implementing provider. It must be registered, get authorisation from the state or territory, lodge evidence of it with the NDIS Commission, report every month (including months with no use), report unauthorised use as a reportable incident within 5 business days, and keep written information about each use.
Key takeaways
- Implementing providers must be registered and audited against the supplementary module on implementing behaviour support plans.
- Monthly reports on regulated restrictive practices are due within 5 business days of month end, and cover months when a practice was not used.
- An unauthorised restrictive practice is a reportable incident, notified within 5 business days of becoming aware.
- Providers must keep written information about each use and tell the specialist behaviour support provider when the plan needs review.
Who is an implementing provider?
The NDIS Commission describes implementing providers as NDIS providers who, in delivering supports, implement behaviour support plans or use regulated restrictive practices. They must be registered if they use regulated restrictive practices, and providers that implement plans containing them are audited against supplementary Practice Standard Module 2A. It is a breach of the NDIS Rules for an unregistered provider to use regulated restrictive practices. The Commission notes that the term is its own, not defined in the legislation.
What must be authorised and lodged?
An implementing provider is responsible for getting authorisation to use a regulated restrictive practice from the authorising body in the state or territory where the person lives, and lodging evidence of the authorisation in the NDIS Commission Portal. Once a specialist behaviour support provider lodges the behaviour support plan, the implementing provider activates the plan, lodges the evidence of authorisation and completes monthly reports.
By when must a behaviour support plan exist?
If a regulated restrictive practice will be used on an ongoing basis, the provider must engage a specialist behaviour support provider to develop a plan. An interim plan is due within 1 month of the practice first being used, and a comprehensive plan within 6 months.
What must be reported, and when?
| Situation | What to do | Timeframe |
|---|---|---|
| Authorised (regulated) practice in a lodged plan | Monthly report in the Registered providers portal, including when a practice is not used | Within 5 business days of month end |
| Unauthorised practice: not in a plan, not authorised by the state or territory process, or not used as the plan says | Report to the NDIS Commission as a reportable incident (the 5 Day Form is the only form needed if it has not caused immediate harm) | Within 5 business days of becoming aware |
| Something happens that requires the plan to be reviewed | Tell the specialist behaviour support provider | As it happens |
Reports can be made against plans that are active, expired or partially active, but not against closed plans. If harm has resulted, the incident is reportable within 24 hours. See the reportable incidents guide.
What should a restrictive practices register hold?
The Commission requires an implementing provider to keep written information about the use of regulated restrictive practices (sections 10 and 15 of the NDIS (Restrictive Practices and Behaviour Support) Rules 2018). The Rules set out what that must cover, so read them for the exact requirement. As a practical example only, not a prescribed format, a register that supports monthly reporting and audit might hold:
| Column | Why it helps |
|---|---|
| Participant and plan reference, plan status | Links each entry to the lodged plan and its schedule of practices |
| Practice used, and where it sits in the plan schedule | Shows whether the use matches an authorised practice |
| Authorisation reference and date lodged | Evidence of state or territory authorisation |
| Date, time, duration and worker | Supports the monthly report and any review |
| Reason, what happened before and after, and the outcome | Supports plan review and shows the use was in line with the plan |
| Month and report status | Shows the monthly report was completed, including nil reports |
| Link to the shift note and any incident record | Ties the register to the evidence chain |
What is ABC data collection, and how does it relate to behaviour support?
ABC data collection records what happened before a behaviour (the antecedent), the behaviour itself, and what followed (the consequence). The NDIS Commission’s practice guide lists it as an example of direct assessment. Only an NDIS behaviour support practitioner can complete the assessment, but support workers should help collect the raw data.
A shift note that records what happened before, during and after a behaviour, in observable terms, gives the practitioner usable raw data. NoteGate supports that by flagging notes that leave this context out. It does not carry out the assessment and it does not write the note.
Where does NoteGate fit?
NoteGate keeps a restrictive practices register alongside the risk, incident and complaints registers, linked to shift notes and incident records. It supports the provider’s documentation. Authorisation, monthly reporting and incident notification remain the provider’s responsibility through the state or territory and the NDIS Commission Portal. See audit registers.
Frequently asked questions
Do I report if I did not use a restrictive practice this month?
Yes. The Commission states monthly reports must be submitted including when a practice is not used, for practices in an active, expired or partially active plan.
What makes a restrictive practice unauthorised?
The Commission says it is unauthorised if it is not in a behaviour support plan, has not been authorised under the state or territory process, or is not used in accordance with the plan.
Can a support worker complete a functional behaviour assessment?
No. The Commission’s practice guide says behaviour support assessment, including functional behaviour assessment, can only be completed by NDIS behaviour support practitioners. Support workers should help by collecting raw data and sharing information with the practitioner.
Sources
- Rules for implementing providers (NDIS Quality and Safeguards Commission, retrieved 20 September 2026)
- Rules for behaviour support and restrictive practices (NDIS Quality and Safeguards Commission, retrieved 20 September 2026)
- Reportable incidents (NDIS Quality and Safeguards Commission, retrieved 19 September 2026)
- NDIS Practice Standards (NDIS Quality and Safeguards Commission, retrieved 19 September 2026)
- Behaviour Support Assessment, including Functional Behaviour Assessment: Practice Guide (Version 1.0, April 2026) (NDIS Quality and Safeguards Commission, retrieved 25 September 2026)
Related
Keep the register linked to the evidence
See how NoteGate ties registers to shift notes and incident records.
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